REPORT

Central Térmica de Temane Project - Waste

Management Plan Moz Power Invest, S.A. and Sasol New Energy Holdings (Pty) Ltd

Submitted to:

Ministry of Land, Environment and Rural Development (MITADER)

Submitted by:

Golder Associados Moçambique Limitada

6th Floor, Millenium Park Building, Vlademir Lenine Avenue No 174

Maputo, Moçambique

+258 21 301 292

18103533-320978-12

April 2019

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Distribution List 12 x copies - National Directorate of Environment (DINAB)

4 x copies - Provincial Directorate for Land, Environment and Rural Development (DPTADER)-I'bane

1 x copy - World Bank Group

1 x copy - SNE, EDM and TEC

1 x copy - Golder project folder

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EXECUTIVE SUMMARY

Introduction

This report presents the Waste Management Plan (WMP) undertaken as part of the Environmental and Social

Impact Assessment (ESIA) process required for a proposed gas to power facility known as the Central Térmica

de Temane (CTT) Project. The Proponent for this application is Moz Power Invest, S.A. (MPI), a company to be

incorporated under the laws of Mozambique under a joint development agreement with Sasol New Energy

Holdings (Pty) Ltd (SNE). Shareholding for MPI is comprised of Electricidade de Mozambique E.P. (EDM) and

Temane Energy Consortium (Pty) Ltd (TEC).

The scope of work for this specialist study reporting to the ESIA contains a project overview; legal framework;

baseline waste environment; waste and wastewater management plans; mitigation and monitoring actions.

The overall objective of the study is to identify all waste streams associated with the project, record their inherent

hazardousness, to identify the potential impacts of these waste streams and to develop measures to mitigate

those impacts that cannot be eliminated or minimized to an acceptable level.

The WMP has been conducted in accordance with the following:

Mozambique legislation;

International conventions, World Bank performance standards and EHS guidelines; and

Sasol’s Environmental Management Plans with respect to waste and wastewater.

Baseline Waste Environment

The waste streams (solid and effluents) generated by the CTT project are expected to be mostly from equipment

and vehicle maintenance at the Logistics and Worker’s Camps. The production of waste and wastewater shall

be dealt with in the following manner:

Wastes destined for reuse and recycling ((as far as is practical) include:

▪ General wastes: paper, wood, textiles, metal and plastic containers, tyres and domestic waste (food waste recommended to be composted); and

▪ Hazardous wastes: printer cartridges (return to supplier for re-inking), waste oils (by gravity separation) and lead acid batteries

Wastes disposed on site include:

▪ Construction and demolition waste (or reuse for construction foundation); and

▪ Garden waste.

Wastes removed by a subcontractor and disposed at an appropriately licensed waste facility include:

▪ General Waste: food waste, contaminated packaging waste, kitchen oil and by-products from emissions controls

▪ Hazardous wastes: medical and laboratory glassware, fluorescent tubes, empty drums, used oil filters, sludge, aerosol cans, single use Personal Protective Equipment and batteries.

Wastewater

With respect to wastewater management the following elements are relevant:

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▪ Domestic wastewater, potentially oil contaminated (POC) water or sewage shall be transferred to Waste Water Treatment Plan (WWTP) for treatment before release to the environment. The effluent will be disposed in line with the Mozambican regulations on effluent water disposal requirements Decree 18/2004 of 2 June (amended by Decree 67/2010 of 31 December) and the World Bank EHS guidelines.

Waste Management Accountabilities

The WMP establishes accountability (producer responsibility) within specified timeframes through various waste minimization, re-use, recycling, recovery and safe treatment and disposal initiatives.

Conclusion and Recommendations

This document presents the Waste Management Plan for the CTT project. It provides a waste management

baseline and details the goals, objectives and targets timeframes for implementation and roles and

responsibilities to achieve a compliant standard of waste management for the CTT project.

Recommendations have been included for measures to reduce risks of performance irregularity imposed by

effluent and waste demands primarily in the logistics and worker’s camps where such risks could result in non-

compliance events. Further recommendations have been made to ensure that the Environmental Management

Plan is updated to improve alignment with the project. Ideally this plan should be reviewed every 5 years in

order to keep up with advances in the waste management industry and to ensure its continued suitability,

adequacy and effectiveness.

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Table of Contents

1.0 PROJECT OVERVIEW ............................................................................................................................... 1

1.1 Introduction ........................................................................................................................................ 1

1.2 Purpose and Objectives of this Document ........................................................................................ 4

1.2.1 Intended Users .............................................................................................................................. 4

2.0 LEGAL FRAMEWORK ............................................................................................................................... 4

2.1 Mozambican Legal Framework ......................................................................................................... 4

2.1.1 Regulatory Authorities ................................................................................................................... 4

2.1.2 Mozambican Regulations .............................................................................................................. 4

2.2 International Guidelines and Conventions ........................................................................................ 6

2.3 Sasol Environmental Management Plans ......................................................................................... 8

3.0 PROJECT DESCRIPTION .......................................................................................................................... 9

3.1 Ancillary Infrastructure .................................................................................................................... 11

3.2 Water and electricity consumption .................................................................................................. 13

3.3 Temporary Beach Landing Site and Transportation Route Alternative .......................................... 13

4.0 WASTE BASELINE ENVIRONMENT ....................................................................................................... 16

4.1 Waste Identification and Classification ........................................................................................... 16

4.2 Non-Hazardous Waste .................................................................................................................... 16

4.3 Hazardous Waste ............................................................................................................................ 16

4.4 Biomedical Waste ........................................................................................................................... 17

4.5 Unidentified Waste .......................................................................................................................... 17

5.0 WASTE MANAGEMENT ACCOUNTABILITIES ...................................................................................... 28

6.0 WASTE MANAGEMENT .......................................................................................................................... 31

6.1 Waste Management Hierarchy........................................................................................................ 31

7.0 WASTE MANAGEMENT PLAN ............................................................................................................... 32

7.1 Non-hazardous Waste Management .............................................................................................. 33

7.1.1 Segregation of Non-hazardous Waste ........................................................................................ 39

7.2 Hazardous Waste Management...................................................................................................... 40

7.3 Wastewater Management ............................................................................................................... 48

7.4 Bio-medical Waste Management .................................................................................................... 54

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7.5 Other Wastes .................................................................................................................................. 56

7.6 Vehicles and Waste Contractors ..................................................................................................... 56

7.6.1 Contractor Inspection .................................................................................................................. 56

7.7 Waste Records ................................................................................................................................ 56

8.0 TRAINING AND INDUCTIONS ................................................................................................................. 57

9.0 INSPECTIONS, AUDITING, REPORTING, AND REVIEW ...................................................................... 57

9.1 Inspections ...................................................................................................................................... 57

9.2 Internal and External Auditing ......................................................................................................... 57

9.3 Reporting to MITADER ................................................................................................................... 58

9.4 Review of this Plan .......................................................................................................................... 58

10.0 REFERENCES .......................................................................................................................................... 59

TABLES

Table 1: Mozambican Regulations ....................................................................................................................... 5

Table 2: Projected Waste Streams and Classification ....................................................................................... 18

Table 3: Waste Management Responsibilities ................................................................................................... 28

Table 4: Required Management Actions for Non-hazardous Waste .................................................................. 33

Table 5: Required Management and Monitoring Actions for Hazardous Waste ................................................ 40

Table 6: Required Management and Monitoring Actions for Hazardous Waste ................................................ 48

Table 7: Required Management and Monitoring Actions for Bio-medical Waste ............................................... 54

FIGURES

Figure 1: Project Location ..................................................................................................................................... 3

Figure 2: Examples of gas to power plant sites (source: www.industcards.com and www.wartsila.com) ......... 10

Figure 3: Conceptual layout of CTT plant site .................................................................................................... 11

Figure 4: Typical beach landing site with barge offloading heavy equipment (source: Comarco) ..................... 12

Figure 5: Example of large equipment being offloaded from a barge. Note the levels of the ramp, the barge and the jetty (source: SUBTECH) .............................................................................................................................. 12

Figure 6: Heavy haulage truck with 16-axle hydraulic trailer transporting a 360 ton generator (source: ALE) .. 13

Figure 7: The three beach landing site options and route options at Inhassoro ................................................ 14

Figure 8: The two main transportation route alternatives from the beach landing sites to the CTT site ............ 15

Figure 9: The waste management hierarchy ...................................................................................................... 31

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APPENDICES

APPENDIX A Annex V of Decree 83/2014 of 31 December

APPENDIX B Characteristics of Waste and Hazardous Substances

APPENDIX C Identification of Hazardous Waste

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ACRONYMS

Acronym Description

CCGT Combined Cycle Gas Turbine

CPF Central Processing Facility

CTT Central Térmica de Temane

EDM Electricidade de Moçambique (Mozambique State Electricity Company)

EIA Environmental Impact Assessment

EMS Environmental Management Systems

EPCM Engineering, Procurement, Construction Management

ESIA Environmental and Social Impact Assessment

ESO Environmental Site Office

FNDS Fundo Nacional de Desenvolvimento

Ha Hectares

HSSE Health, Safety, Security and Environment

IFC International Finance Corporation

KV Kilovolts

MITADER Ministry of Land, Environment and Rural Development

MSDS Material Safety Data Sheet

MW Megawatt

OCGE Open Cycle Gas Engines

POC Potentially Oily Contaminated

PPZ Partial Protection Zone

SEPI Sasol Exploration Production International

SNE Sasol New Energy Holdings

SPT Sasol Petroleum Temane Lda

TDS Total Dissolved Solids

WTN Waste Transfer Note

WWTP Waste Water Treatment Plant

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GLOSSARY OF TERMS

Term Description

Bio-Medical Waste Mozambican waste Decree 8/2003 of 18 February defines bio-medical waste as

waste resulting from medical or veterinary diagnosis, treatment and research.

Contractor The organisation that is appointed to represent the Proponent and to manage the

sub-contractors’ activities.

Disposal

The burial, deposit, discharge, abandoning, dumping, placing or release of waste

into, or onto, any land. In accordance with National Law it is the use of any of the

operations specified in Annex V of Decree 83/2014 of 31 December 2014 (see

Appendix A).

Domestic Waste Waste excluding hazardous waste, that emanates from premises that are used

wholly or mainly for residential, educational, health care, sport or recreation

purposes.

Environmental

Coordinator (EC)

A permanent employee with environmental experience, based in Mozambique, and

responsible for the coordination of the environmental and social impact

management of the project.

Environmental Site

Officer (ESO)

This is a person with environmental training who is responsible for the day-to-day

environmental management of construction activities.

Environmental

Specialists

These are either personnel employed by the Proponent or external specialists called

in for specific environmental aspects as defined by the environmental coordinator.

Hazardous Waste

Hazardous waste is waste that contains organic or inorganic elements or compounds with risk characteristics for being flammable, explosive, corrosive, toxic, infectious or radioactive, or for exhibiting any other characteristic that constitutes hazard for the health and safety of humans or other living creatures and for environmental quality.

Inert waste Inert waste is waste that does not undergo any significant physical, chemical or biological transformation after disposal; does not burn, react physically or chemically biodegrade or otherwise adversely affect any other matter or environment, with which it may come into contact; and does not impact negatively on the environment, because of its pollutant content and because toxicity of its leachate is insignificant.

Non-Hazardous

Wastes

Non-hazardous waste is waste that does not undergo any significant physical,

chemical or biological transformation after disposal; does not burn, react physically

or chemically biodegrade or otherwise adversely affect any other matter or

environment, with which it may come into contact; and does not impact negatively

on the environment, because of its pollutant content and because the toxicity of its

leachate is insignificant. It is therefore waste with no risk characteristics according

to National Law

Pollution Prevention The reduction in volume and/or toxicity of waste prior to discharge or disposal.

Proponent

Refers to Moz Power Invest, S.A. (MPI) under a joint development agreement with

Sasol New Energy Holdings (Pty) Ltd (SNE). Shareholding for MPI is comprised of

Electricidade de Mozambique E.P. (EDM) and Temane Energy Consortium (Pty)

Ltd (TEC).

Recovery The controlled extraction of a material or the retrieval of energy from waste to

produce a product.

Recycle A process where waste is reclaimed for further use, which process involves the

separation of waste from a waste stream for further use and the processing of that

separated material as a product or raw material.

Re-use To utilise articles from the waste stream again for a similar or different purpose

without changing the form or properties of the articles.

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Source Reduction

(Minimisation)

The reduction or elimination of waste at its source. Involves the evaluation of the

facility and its processes, operating practices, raw materials and waste generating

processes.

Special Wastes

Based on Basel convention, special wastes are those that do not fit into the

hazardous, non-hazardous, decomposable, or inert waste categories or which have

special waste disposal practices. The naturally occurring radioactive materials

(NORM) waste fall into this category.

SPT Refers to Sasol Petroleum Temane Lda, which is a subsidiary of Sasol Petroleum

International (Pty) Ltd. The company, Sasol Petroleum Temane Lda, is based in

Mozambique, having its principle place of business at Avenida 25 de Setembro,

420, Predio JAT, 2 Andar, Sala L4, Caixa Postal 4356, Maputo, República de

Moçambique.

Treatment

Any method, technique or process that is designed to change the physical, biological, or chemical character or composition of a waste in order to minimise the impact of the waste on the environment prior to further use or disposal.

Treatment is divided into four categories: Thermal, Chemical, Biological, and

Physical.

Waste Waste is any unwanted substance or object which is disposed of, is intended to be

disposed of, or is required to be disposed of by the provisions of National Law.

Waste disposal facility Any site or premise used for the accumulation of waste with the purpose of

disposing of that waste at that site or on that premise.

Waste transfer facility A facility that is used to accumulate and temporarily store waste before it is

transported to a recycling, treatment or waste disposal facility.

Work sites Areas within which the Proponent and Contractor activities take place, including the

construction right of way, Transmission lines, and the like but excluding the Worker’s

Camp and Logistics Camp

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1.0 PROJECT OVERVIEW

1.1 Introduction

The Mozambican economy is one of the fastest growing economies on the African continent with electricity

demand increasing by approximately 6-8% annually. In order to address the growing electricity demand faced

by Mozambique and to improve power quality, grid stability and flexibility in the system, Moz Power Invest, S.A.

(MPI), a company to be incorporated under the laws of Mozambique and Sasol New Energy Holdings (Pty) Ltd

(SNE) in a joint development agreement is proposing the construction and operation of a gas to power facility,

known as the Central Térmica de Temane (CTT) project. MPI’s shareholding will be comprised of EDM and

Temane Energy Consortium (Pty) Ltd (TEC). The joint development partners of MPI and SNE will hereafter be

referred to as the Proponent. The Proponent propose to develop the CTT, a 450MW natural gas fired power

plant.

The proposed CTT project will draw gas from the Sasol Exploration and Production International (SEPI) gas

well field via the phase 1 development of the PSA License area, covering gas deposits in the Temane and

Pande well fields in the Inhassoro District and the existing Central Processing Facility (CPF). Consequently, the

CTT site is in close proximity to the CPF. The preferred location for the CTT is approximately 500 m south of

the CPF. The CPF, and the proposed site of the CTT project, is located in the Temane/Mangugumete area,

Inhassoro District, Inhambane Province, Mozambique; and approximately 40 km northwest of the town of

Vilanculos. The Govuro River lies 8 km east of the proposed CTT site. The estimated footprint of the CTT power

plant is approximately 20 ha (see Figure 1).

The proposed project will draw gas from either the Sasol Exploration Production International (SEPI) gas well

field via the existing Central Processing Facility (CPF) or from an alternative gas source. Consequently, the CTT

site is in close proximity to the CPF. The preferred location for the CTT is approximately 500 m south of the

CPF. The CPF, and the proposed site of the CTT project, is located in the Temane/Mangugumete area,

Inhassoro District, Inhambane Province, Mozambique; and approximately 40 km northwest of the town of

Vilanculos. The Govuro River lies 8 km east of the proposed CTT site. The estimated footprint of the CTT power

plant is approximately 20 ha.

Associated infrastructure and facilities for the CTT project will include:

1) Electricity transmission line (400 kV) and servitude; from the proposed power plant to the proposed

Vilanculos substation over a total length of 25 km running generally south to a future Vilanculos substation.

[Note: the development of the substation falls outside the battery limits of the project scope as it is part of

independent infrastructure authorised separately (although separately authorised, the transmission line will

be covered by the Project ESMP, and the Vilanculos substation is covered under the Temane Transmission

Project (TTP) Environmental and Social Management Plans). Environmental authorisation for this

substation was obtained under the STE/CESUL project. (MICOA Ref: 75/MICOA/12 of 22nd May 2012)];

2) Piped water from one or more borehole(s) located either on site at the power plant or from a borehole

located on the eastern bank of the Govuro River (this option will require a water pipeline approximately

11km in length);

3) Access road; over a total length of 3 km, which will follow the proposed water pipeline to the northeast of

the CTT to connect to the existing Temane CPF access road;

4) Gas pipeline and servitude; over a total length of 2 km, which will start from the CPF high pressure

compressor and run south on the western side of the CPF;

5) Additional nominal widening of the servitude for vehicle turning points at points to be identified along these

linear servitudes;

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6) A construction camp and contractor laydown areas will be established adjacent to the CTT power plant

footprint; and

7) Transhipment and barging of equipment to a temporary beach landing site and associated logistics camp

and laydown area for the purposes of safe handling and delivery of large oversized and heavy equipment

and infrastructure to build the CTT. The transhipment consists of a vessel anchoring for only approximately

1-2 days with periods of up to 3-4 months between shipments over a maximum 15 month period early in

the construction phase, in order to offload heavy materials to a barge for beach landing. There are 3 beach

landing site options, namely SETA, Maritima and Briza Mar (Figure 7). The SETA site is considered to be

the preferred beach landing site for environmental and other reasons; it therefore shall be selected unless

it is found to be not feasible for any reason; and

8) Temporary bridges and access roads or upgrading and reinforcement of existing bridges and roads across

sections of the Govuro River where existing bridges are not able to bear the weight of the equipment loads

that need to be transported from the beach landing site to the CTT site. Some new sections of road may

need to be developed where existing roads are inaccessible or inadequate to allow for the safe transport

of equipment to the CTT site. The northern transport route via R241 and EN1 is considered as the preferred

transport route (Figure 8) on terrestrial impacts; however, until the final anchor point is selected, and the

barge route confirmed, the marine factors may still have an impact on which is deemed the overall

preferable route.

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Figure 1: Project Location

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1.2 Purpose and Objectives of this Document

The objective of the Waste Management Plan (WMP) is to provide a system for the identification, classification,

minimization, handling, storage and treatment/disposal of all wastes generated as a result of the CTT project

activities and associated infrastructures, on the surrounding environment during the project lifecycle, to ensure:

Compliance with Mozambique waste management legislation;

Conformation with oil and gas World Bank performance standards and World Bank EHS guidelines; and

Implementation of industry best practice waste management procedures, in order to eliminate or mitigate potential impacts on the environment and human health.

In the long term, this will reduce waste management costs, environmental liabilities, and risks.

The WMP elaborates the requirements with respect to the definition and assessment of the potential impacts of

all types of wastes expected to be produced from the project activities. The types of waste and wastewater

generated during the CTT project lifecycle are described.

1.2.1 Intended Users

This document is applicable to all of the Proponent’s activities undertaken during the CTT project. It is also

applicable to contractors working under business agreements with the proponent for the CTT project.

2.0 LEGAL FRAMEWORK

This section summarizes the current national and international legislation, standards and guidelines that

regulate environmental matters relevant to the management of waste.

2.1 Mozambican Legal Framework

2.1.1 Regulatory Authorities

Ministry of Land, Environment and Rural Development (MITADER)

MITADER is responsible for directing the implementation of environmental policy, coordinating, advising and

auditing. Under waste management, it is the Ministry’s responsibility for the following:

a) To issue and disseminate binding rules on the procedures to be followed under waste management;

b) To carry out the environmental licensing of facilities or places of storage and / or disposal waste;

c) To monitor compliance with the provisions of the regulations and the rules on waste management;

d) To ensure public participation in the licensing process provided in paragraph (b) of this number, as well

as access to relevant information on waste management.

2.1.2 Mozambican Regulations

The legal framework summarised below are the main laws, policies, directives and guidelines applicable to the

CTT project activities.

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Table 1: Mozambican Regulations

Name Summary

Environment

Constitution of the

Republic of

Mozambique, 16

November 2004

The constitution establishes the fundamental right to a balanced environment and

the corresponding duty to defend it. The constitution further declares natural

resources in the soil and the subsoil, in inland waters, in territorial waters, on the

continental shelf, and in the exclusive economic zone to be State property.

Environmental Law

(Decree 20/1997 of 1

October)

The Environment Law defines a number of fundamental environmental

management concepts and principles, establishing the basic institutional

framework for environmental protection; establishing a general norm which

prohibits all activities that cause environmental damage exceeding legally defined

limits (pollution in particular); stipulating special norms to protect the environment

(protecting biodiversity in particular); providing for a set of environmental

management instruments (the environment license, the environmental impact

assessment process and the environmental audit); and describing the system

inspection, offences and penalties for non-compliance.

Environmental Quality and Prevention of Pollution

Regulations on

Environmental Quality

and Emission

Standards (Decree

18/2004 of 2 June), as

amended by Decree

67/2010 of 31

December

The Regulations are in terms of Article 10 of the Environment Law, and are

concerned with environmental quality standards for air, water and soil. Regarding

air, the Regulations establish standards for emission limits related to specified

industrial processes and for ambient air quality. Regarding water, the Regulations

specify compliance requirements for industrial liquid effluent that is discharged

into the environment. Standards for different industries are set out, including

domestic discharges (understood to mean discharges from sewage treatment

works) and discharges from the petrochemical industry.

The location of an emission from any source must be determined during the

environmental licensing process so as to ensure that there is no change in the

quality of the water in the receiving body, preventing the use of its water for other

purposes.

Regulation for

Prevention of Pollution

and Protection of

Marine and Coastal

Environment (Decree

45/2006 of 30

November)

Approves the Regulation for the prevention of marine pollution and environmental

protection of the coastal areas in order to protect the marine and fresh water

ecosystems. This Regulation aims to prevent marine pollution caused by vessels,

platforms, or any other polluting infrastructure which illegally perform any

discharge into the waters (including inland waters), of waste waters, residues, or

any polluting substance.

Waste Management

Regulations on Urban

Solid Waste

Management (Decree

The Regulations establish rules on the production, emission or disposal in the soil

and subsoil, in water or the air, of any toxic or polluting substance, as well as the

execution of activities that accelerate deterioration of the environment, to avoid or

minimize their negative impact on health and the environment.

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Name Summary

94/2014 of 31

December)

It applies to all natural and legal, public and private persons involved in the

production and management of solid urban waste and the production and

management of industrial and medical waste.

The Decree in its Article 8 and Annex I (Waste Management Plan), mandates all

the public or private entities that perform waste management activities, to develop

and implement a waste management plan. The integrated management plans of

municipal solid waste are valid for a period of five (5) years from the date of

approval by the Municipal Assemblies or Governments.

Regulation on the

Management of

Biomedical Solid Waste

(Decree 8/2003 of 18

February)

Establishes the rules relative to biomedical waste management, with the aim of

safeguarding medical service employees’ health and safety and the public in

general and minimize impact of such waste on the environment. It requires all

medical units, research institutes and companies covered by this regulation to

develop a biomedical waste management plan, line a) of nº 2, Article 4.

Regulation on

Hazardous Waste

Management (Decree

83/2014 of 31

December)

This Decree approves the Regulation on Hazardous Waste Management and

aims at establishing general rules related to waste disposal, including: the

establishment of rules for the production and management of hazardous waste in

the country and applies to all natural and legal, public and private persons

involved in hazardous waste management or import, distribution and sale of

expired used or new tires.

Petroleum Operations

Environmental

Regulations for

Petroleum

Operations,

(Decree

56/2010 of 22

November).

These Regulations address EIA requirements for oil and gas related activities.

Under this statute, petroleum operations are defined as “all or some of the

operations related to exploration, development, production, separation and

treatment, storage, transport and sale or delivery of petroleum at the agreed

supply point in the country, including the operations of natural gas processing and

the closure of all operations concluded”. These Regulations clearly set out the

EIA procedures for petroleum operations and the measures to be observed with

regard to prevention, control, mitigation and rehabilitation of the environment.

Petroleum Law

(Law 21/2014 of 18

August).

This law provides the framework for all aspects of petroleum related activities in

Mozambique, including the rights to use and benefit from land and for Rights of

Way to be designated as Partial Protection Zones and for rights holders to this

land to be compensated. It also covers environmental protection and safety and

requires EIAs for petroleum related activities for approval by relevant authorities;

and provides for environmental controls of pollution, reporting of accidental

discharges, and rehabilitation of damaged sites.

2.2 International Guidelines and Conventions

The following are international conventions and guidance related to waste management as is applicable to the

CTT project:

World Bank Group (OP4.03) Performance Standards and World Bank Environmental, Health and

Safety (EHS) Guidelines

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The WB EHS guidelines provide guidance for the following:

▪ Information in support of actions for avoiding, minimizing, and controlling EHS impacts during the

construction, operation, and decommissioning phases of a project or development of a facility;

▪ The implementation of the IFC Performance Standards, particularly on those aspects related to

Performance Standard 3: Pollution Prevention & Abatement and aspects of occupational and

community health and safety;

▪ Assisting decision makers with relevant industry background and technical information;

▪ Management of produced water/wastewater – guidelines for reduction, reuse and disposal; and

▪ Treatment and disposal of general waste waters (sewage, drainage and storm water).

In the event of a host country’s regulations differing from the levels and measures presented in the WB EHS

Guidelines, projects will be expected to comply with whichever is more stringent. If less stringent levels or

measures are appropriate in view of specific project circumstances, a full and detailed justification for any

proposed deviation/alternatives should be provided.

▪ Performance Standard (PS) PS3: Resource Efficiency and Pollution Prevention. This PS requires the

investor to avoid or minimise adverse human impacts on human health and the environment by

avoiding or minimising pollution from project activities.

▪ Air Quality - Air emissions guidelines are outlined in the World Health Organisation (WHO) Air Quality

Guidelines Global Update. EHS guidelines for air quality management include the identification of

possible risks and hazards associated with the project as early on as possible and understand the

magnitude of the risks; the potential consequences to workers, communities, or the environment if

these hazards are not adequately managed or controlled. Impacts to air quality should be prevented

or minimised by ensuring that emissions to air do not result in pollutant concentrations exceeding the

relevant ambient air quality guidelines or standards.

General WB EHS Guidelines: Environmental Waste Management

These guidelines apply to projects that generate, store, or handle any quantity of waste across a range of

industry sectors. It provides guidance in terms of general non-hazardous waste, hazardous waste and waste

monitoring options. The Proponents’ commitment to waste minimisation, reuse and recycle is audited against

the intent of these general EHS guidelines.

Sludge and other discarded material, including solid, liquid, semi-solid, or gaseous material resulting from

industrial operations needs to be evaluated on a case-by-case basis to establish whether it constitutes a

hazardous or a non-hazardous waste. Facilities that generate and store wastes should practice the following:

▪ Establishing waste management priorities at the outset of activities;

▪ Establishing a waste management hierarchy that considers first prevention then reduction, reuse,

recovery, recycling, removal and finally disposal of wastes;

▪ Avoiding or minimizing the generation of waste materials, as far as practicable; and

▪ Where waste generation cannot be avoided, minimize, recover and reuse waste

General WB EHS Guidelines: Power Plants

The EHS Guidelines for Thermal Power Plants includes information relevant to the waste streams and

management of waste.

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Recommended measures to prevent, minimize, and control the volume of solid wastes from thermal power

plants include recycling of solid wastes in uses such as cement and other concrete products, construction

(roads), disposal of solid wastes in permitted landfills and dry handling of solid wastes, in particular fly ash.

South African National Standard (SANS) 101031 - Mozambique has not promulgated its own noise

regulations and reference is usually made to other standards and guidelines in cases where noise impacts

need to be assessed. SANS 101031 is aligned with World Health Organisation (WHO) 2 guidelines.

Conventions

▪ The Basel Convention (1992) (on the Control of Transboundary Movements of Hazardous Wastes and

Their Disposal) to which Mozambique has acceded (1997), controls the movement, storage, transport,

treatment, reuse, recycling, recovery and final disposal of hazardous waste as well as requiring

producers of hazardous waste to dispose of their waste in an environmentally responsible manner

close to where it is generated.

▪ The Bamako Convention (1991) is supplementary to the Basel Convention and specifically covers the

movement of hazardous waste into or between signatory African countries. Mozambique acceded this

convention in 1999.

▪ The Stockholm Convention (2004) on Persistent Organic Pollutants is a global treaty to protect human

health and the environment from chemicals that remain intact in the environment for long periods,

become widely distributed geographically, accumulate in the fatty tissue of humans and wildlife, and

have harmful impacts on human health or on the environment. Mozambique acceded this convention

in 2006.

▪ Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals

and Pesticides in International Trade (1998).

▪ The European Waste Incineration Directive, Directive 2000/76/EC on the Incineration of Waste. This

directive provides regulations for the incineration of household and hazardous waste in Europe. The

aim of the Waste Incineration Directive is to prevent or to reduce, as far as possible, negative effects

on the environment caused by the incineration and co-incineration of waste.

▪ Basel Convention Technical Guidelines on Incineration on Land, 2002. These guidelines focus on the

disposal of hazardous waste by thermal processes.

2.3 Sasol Environmental Management Plans

This WMP is supported by Sasol’s Environmental Management Plans (EMPs) namely:

Exploration, Appraisal and Development Activities in the Sasol License Areas EMPs (2017):

▪ Construction (Infrastructure) Environmental Management Plan;

▪ Framework Decommissioning and Rehabilitation Plan (f-DRP);

▪ Drilling Environmental Management Plan;

▪ Operational Environmental Management Plan;

▪ Oil Spill Response Plan;

Central Processing Facility’s (Sasol Petroleum Temane Lda, 2013):

▪ Construction Environmental Management Plan.

The EMPs take into account the following overall project processes and outputs with regard to the waste and

wastewater (effluent) impacts:

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▪ Site water management:

− Stormwater management; and

− Effluent management.

▪ Solid waste management:

− General;

− Waste storage and transport;

− Waste disposal;

− Recycling of waste; and

− Development and operation of waste disposal sites;

▪ Hazardous materials management and disposal:

− General;

− Management of hazardous materials;

− Storage and handling of hazardous materials;

− Disposal of hazardous waste;

− Disposal of medical waste;

− Incineration of waste; and

− Contaminated soils.

The EMPS further state (in the Environmental Management Structures) that the CTT Operations Manager shall

ensure that all parties comply with all the requirements of the EIS and EMP to control waste, avoid pollution and

ensure that waste is minimised.

3.0 PROJECT DESCRIPTION

The CTT project will produce electricity from natural gas in a power plant located 500m south of the CPF. The

project will consist of the construction and operation of the following main components:

Gas to Power Plant with generation capacity of 450MW;

Gas pipeline (±2 km) that will feed the Power Plant with natural gas from the CPF;

400kV Electrical transmission line (± 25 km) with a servitude that will include a fire break (vegetation

control) and a maintenance road to the Vilanculos substation. The transmission line will have a partial

protection zone (PPZ) of 100m width. The transmission line servitude will fall inside the PPZ;

Water supply pipeline from one or more borehole(s) located either on site or at borehole(s) located east of

the Govuro River;

Surfaced access road to the CTT site and gravel maintenance roads within the transmission line and

pipeline servitudes;

Temporary beach landing structures at Inhassoro for the purposes of delivery of equipment and

infrastructure to build the power plant. This will include transhipment and barging activities to bring

equipment to the beach landing site for approximately 1-2 days with up to 3-4 months between shipments

over a period of approximately 8-15 months;

Construction camp and contractor laydown areas adjacent to the CTT power plant site; and

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Temporary bridge structures across Govuro River and tributaries, as well possible new roads and/or road

upgrades to allow equipment to be safely transported to site during construction.

Figure 2: Examples of gas to power plant sites (source: www.industcards.com and www.wartsila.com)

The final selection of technology that will form part of the power generation component of the CTT project has

not been determined at this stage. The two power generation technology options that are currently being

evaluated are:

Combined Cycle Gas Turbine (CCGT); and

Open Cycle Gas Engines (OCGE).

Please refer to Chapter 4 of the main ESIA document for further details on the technology option.

At this early stage in the project a provisional layout of infrastructure footprints, including the proposed linear

alignments is indicated in Figure 1. A conceptual layout of the CTT plant site is shown below in Figure 3.

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Figure 3: Conceptual layout of CTT plant site

3.1 Ancillary Infrastructure

The CTT project will also include the following infrastructure:

Maintenance facilities, admin building and other buildings;

Telecommunications and security;

Waste (solid and effluent) treatment and/or handling and disposal by third party;

Site preparation, civil works and infrastructure development for the complete plant;

Construction camp (including housing/accommodation for construction workers); and

Beach landing laydown area and logistics camp.

The heavy equipment and pre-fabricated components of the power plant will be brought in by ship and

transferred by barge and landed on the beach near Inhassoro. The equipment and components will be brought

to site by special heavy vehicles capable of handling abnormally heavy and large dimension loads. Figure 4,

Figure 5 and Figure 6 show examples of the activities involved with a temporary beach landing site, offloading

and transporting of large heavy equipment by road to site.

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Figure 4: Typical beach landing site with barge offloading heavy equipment (source: Comarco)

Figure 5: Example of large equipment being offloaded from a barge. Note the levels of the ramp, the barge and the jetty (source: SUBTECH)

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Figure 6: Heavy haulage truck with 16-axle hydraulic trailer transporting a 360 ton generator (source: ALE)

3.2 Water and electricity consumption

The type, origin and quantity of water and energy consumption are still to be determined based on the selected

technology to construct and operate the CTT plant. At this stage it is known that water will be sourced from

existing boreholes located on site or east of the Govuro River for either of the technology options below:

Gas Engine: ± 12 m3/day; or

Gas Turbine (Dry-Cooling): ± 120 – 240 m3/day.

3.3 Temporary Beach Landing Site and Transportation Route Alternative

As part of the CTT construction phase it was considered that large heavy equipment and materials would need

to be brought in by a ship which would remain anchored at sea off the coast of Inhassoro. Equipment and

materials would be transferred to a barge capable of moving on the high tide into very shallow water adjacent

to the beach to discharge its cargo onto a temporary off-loading jetty (typically containers filled with sand) near

the town of Inhassoro. As the tide changes, the barge rests on the beach and off-loading of the equipment

commences.

Currently, the SETA beach landing site is the preferred beach landing site together with the road route option

to be used in transporting equipment and materials along the R241 then the EN1 then via the existing CPF

access road to the CTT site near the CPF. Figure 7 and Figure 8 indicate the beach landing site and route

transportation option. The alternative beach landing sites of Maritima and Briza Mar are still being evaluated

as potential options, as well as the southern transport route, which would also require road upgrades and a

temporary bridge construction across the Govuro at the position of the existing pipe bridge. As part of the

transportation route, the Grovuro River bridge may need to be upgraded / strengthened to accommodate the

abnormal vehicle loads. Alternatively, a temporary bypass bridge will be constructed adjacent to the existing

bridge.

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Figure 7: The three beach landing site options and route options at Inhassoro

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Figure 8: The two main transportation route alternatives from the beach landing sites to the CTT site

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4.0 WASTE BASELINE ENVIRONMENT

4.1 Waste Identification and Classification

All waste generated by the Proponent on the CTT project will be classified in accordance with the Mozambican

applicable legislation, namely the Regulations on Urban Solid Waste Management Regulations (Decree

94/2014 of 31 December) and the Regulations on Hazardous Waste Management (Decree 83/2014 of 31

December), which classifies hazardous waste based on specific characteristics.

4.2 Non-Hazardous Waste

Non-hazardous waste includes a wide range of materials that can be recycled (depending on if they have been

source segregated) and does not exhibit any hazardous properties. Examples include domestic waste such as

food, packaging materials, scrap metals, various metals and wood.

Article 14 of the regulations on Urban Solid Waste Management classifies non-hazardous waste according to

the following categories:

a) Organic materials;

b) Paper or cardboard;

c) Rubble;

d) Plastic;

e) Glass;

f) Metal;

g) Textiles;

h) Rubber;

i) Bulky household waste;

j) Special waste.

With the exception of special wastes, which is not explicitly defined in the regulation, it is expected that all the

above waste types will be generated by the CTT project to some extent, with the quantities of these wastes

varying depending on the activity.

It should be noted that some products are considered non‐hazardous prior to their intended use yet may become

hazardous once used and may contain a range of hazardous chemicals or contaminants (e.g. oil contaminated

rages and wipes).

4.3 Hazardous Waste

Hazardous waste as defined by the Mozambican law, are those listed in Annex IX of the hazardous waste

regulation, which can be potentially harmful to human health or has the potential to damage the environment

and demonstrates one or more of the hazard characteristics listed in Annex III of the regulation. They include

wastes which have any of the following characteristics:

Explosive;

Flammable;

Toxic;

Infectious;

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Radioactive; and

Other characteristics that constitute a danger to the life or health of humans and other living beings and

to the quality of the environment.

The characteristics of hazardous wastes are further described in Annex III of the same decree (Appendix B).

Despite being hazardous, several types of hazardous wastes can and should be recycled, to the extent where

technically feasible or possible (e.g. waste oils and solvents).

4.4 Biomedical Waste

Bio-medical waste is regulated by Decree 8/2003, Bio-medical Waste Management Regulations and it refers to

waste resulting from diagnosing, treatment (the waste that would originate from the project clinic) as well as

human and veterinary science survey. The Decree indicates how bio‐medical waste should be separated,

identified, stored, removed, transported and disposed. Bio‐medical waste will be separated into the following

types:

Infectious waste;

“Sharps” (needles, knives etc.);

Anatomical waste;

Ordinary waste; and

Pharmaceutical waste.

Only a limited amount of anatomical waste is expected to be generated from the CTT project. No surgical

procedures will be done on site. For certain minor cases, minor surgical procedures may be performed in the

Camp’s Clinic in an emergency. In such an event, the appropriate procedure for the storage and disposal of

medical waste shall be adhered to.

4.5 Unidentified Waste

Where materials of unknown type or composition are identified, they will be treated as hazardous (precautionary

approach). Raw material MSDS sheets, process knowledge, sampling and analyses, as required, will be used

to classify unknown wastes for the purposes of storage, transportation, recycling/reuse, and disposal.

If the material is determined to be waste and the risks have been assessed, the integrity of the storage container,

if any, will be evaluated and the waste will be transferred to an appropriate management area within the

Proponent Camp’s waste storage area where it can be properly managed and / or disposed.

All unknown waste shall be managed and disposed in discussion with the Environmental Coordinator.

A list of wastes anticipated to be generated during the CTT project activities is presented in Table 2 together

with the provisional classification for each waste and preferred treatment/disposal route.

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Table 2: Projected Waste Streams and Classification

Source of Waste Waste Stream

Beach Landing/

Logistics Camp

Worker’s

Construction

Camp

Power Plant Access

Roads/Bridges

from Beach

Landing

Installation

400kV line

Classification Reuse/Recycle/

Treatment/Disposal

Route

Site clearance Wood or

vegetation

X X Non‐hazardous Reuse and/or recycle.

Wood-chipping may be

used for composting.

Surplus

excavated

material

X X Non‐hazardous Re-use if possible in the

vicinity of works (bunding /

landscaping).

Supply of

materials

Containers

(metal, plastics,

etc.)

X X X Non‐hazardous Reuse and/or recycle

uncontaminated source

separated plastic, ferrous

and non-ferrous metals at

local recycler or scrap

metal merchant

respectively.

Transport

Infrastructure

(pipelines, access

roads)

X X Non‐hazardous Reuse and/or recycle

uncontaminated source

separated plastic, and

reuse of inert aggregate in

construction of roads.

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Source of Waste Waste Stream

Beach Landing/

Logistics Camp

Worker’s

Construction

Camp

Power Plant Access

Roads/Bridges

from Beach

Landing

Installation

400kV line

Classification Reuse/Recycle/

Treatment/Disposal

Route

Storage and

Transport of

Equipment

Lubricating Oils

from the

equipment

X X X Hazardous Recycling of oil by gravity

separation or

centrifugation (or reuse as

a fuel source e.g. as RDF

in cement kilns).

Accommodation

and kitchen

Food waste X Non‐hazardous Where possible used as

compost or animal-feed.

Otherwise, collection and

disposal by third party

waste contractor at

approved landfill.

Packaging,

general waste

Various

contaminated

packaging waste

X X X Non‐hazardous,

combustible

Collection and disposal by

third party waste

contractor at approved

landfill if contaminated

and unsuitable for reuse

or recycling.

Accommodation

areas

Textiles X Non‐hazardous Reuse and/or recycle to

the local market/charity.

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Source of Waste Waste Stream

Beach Landing/

Logistics Camp

Worker’s

Construction

Camp

Power Plant Access

Roads/Bridges

from Beach

Landing

Installation

400kV line

Classification Reuse/Recycle/

Treatment/Disposal

Route

Offices Paper and

cardboard

X X Non‐hazardous Reuse and/or recycle

paper and card.

Otherwise, disposal by

third party waste

contractor if contaminated

with food waste.

Accommodation

areas, offices

Plastics X X X Non‐hazardous Reuse and/or recycle.

Camping

Facility,

Accommodation

areas,

Maintenance

works

Wastewater

(Sewage)

X Hazardous Process through a

wastewater treatment

plant before discharging

effluent to the

environment. Sewage

solids that are well treated

with no volatiles or

pathogens remaining may

be used in land spreading

or composting.

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Source of Waste Waste Stream

Beach Landing/

Logistics Camp

Worker’s

Construction

Camp

Power Plant Access

Roads/Bridges

from Beach

Landing

Installation

400kV line

Classification Reuse/Recycle/

Treatment/Disposal

Route

Protective

contaminated

clothes

X X X Hazardous If PPE is reusable, follow

the specified cleaning and

maintenance instructions.

Otherwise, dispose of

contaminated single use

PPE for collection by third

party waste contractor.

Pesticides X X Hazardous Follow instructions on

pesticide product label,

i.e. return to supplier or

incineration most likely

required.

Aerosol

Propellants

X X Hazardous Collection and disposal by

third party waste

contractor for proper

handling (separation,

recycling). Aerosols may

be degassed under a

nitrogen blanket and metal

component recycled.

Accommodation

areas, offices,

Kitchen

Glass X Non‐hazardous Reuse and/or recycle.

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Source of Waste Waste Stream

Beach Landing/

Logistics Camp

Worker’s

Construction

Camp

Power Plant Access

Roads/Bridges

from Beach

Landing

Installation

400kV line

Classification Reuse/Recycle/

Treatment/Disposal

Route

Accommodation

areas, offices,

Kitchen

Electronic

equipment

X Hazardous Collection and recycling of

e-waste by suitable

approved contractors.

Otherwise, appropriate

treatment or disposal.

Construction Metals

X X X Non‐hazardous Reuse and/or recycle

ferrous and nonferrous

metals.

Wires X X X Non‐hazardous Reuse and/or recycle

uncontaminated source

separated, ferrous and

non-ferrous metals at local

recycler or scrap metal

merchant respectively.

Kitchen Kitchen oil /

grease

X Non‐hazardous Collection and disposal by

third party waste

contractor for recycling or

treatment.

Offices Printer cartridges X Hazardous Recycle by returning to

supplier for re-inking.

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Source of Waste Waste Stream

Beach Landing/

Logistics Camp

Worker’s

Construction

Camp

Power Plant Access

Roads/Bridges

from Beach

Landing

Installation

400kV line

Classification Reuse/Recycle/

Treatment/Disposal

Route

Accommodation

areas, offices,

kitchen,

workshops

Hazardous

wastes (e.g. small

batteries,

Fluorescent and

sodium lamps)

X X X Hazardous Collection and recycling of

batteries (lead acid battery

recycling) and recycling of

e-waste by suitable

approved contractors.

Otherwise, appropriate

treatment or disposal.

First aid /

medical

treatment

centres

Bio-medical

wastes

X Bio‐medical Collection by third party

waste contractor for

treatment. Most bio-

medical wastes may be

treated until rendered non-

hazardous for onward

disposal, and only limited

amounts of toxic

chemicals/laboratory

waste or sharps (needles)

require incineration.

Vehicle

workshops

Tyres X Non‐hazardous Recycle.

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Source of Waste Waste Stream

Beach Landing/

Logistics Camp

Worker’s

Construction

Camp

Power Plant Access

Roads/Bridges

from Beach

Landing

Installation

400kV line

Classification Reuse/Recycle/

Treatment/Disposal

Route

Vehicle

workshops

Waste Oil, Oil

filters, Lubricating/

Hydraulic Oil

X X Hazardous Recycle waste oils.

Collection and disposal or

non-recyclable waste at

hazardous landfill by third

party waste contractor

Construction /

maintenance

works

Lead‐acid

batteries,

X X Hazardous Recycle lead acid

batteries. Collection and

disposal or non-recyclable

waste at hazardous landfill

by third party waste

contractor

Waste Oil from

Transformers,

Lubricating/

Hydraulic Oil,

Sludge

X X X X Hazardous Recycle waste oils.

Collection and disposal of

non-recyclable waste at

hazardous landfill by third

party waste contractor

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Source of Waste Waste Stream

Beach Landing/

Logistics Camp

Worker’s

Construction

Camp

Power Plant Access

Roads/Bridges

from Beach

Landing

Installation

400kV line

Classification Reuse/Recycle/

Treatment/Disposal

Route

Contaminated

Soils

X X X X Hazardous Collect soil samples for

waste disposal profiling as

necessary to fulfil

appropriate soil disposal

requirements or Collection

and disposal by third party

waste contractor at project

approved landfill.

Paints X X Hazardous Collection and disposal by

third party waste

contractor at project

approved landfill.

Emissions

controls

By-products from

air pollution

controls

X Non-hazardous Collection and disposal by

third party waste

contractor at project

approved landfill.

Construction

activities,

demolition (after

Inert waste –

concrete rubble

and washout, grit

X X X Non‐hazardous Reuse as aggregate in

crusher and screener for

construction (as

foundation material).

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Source of Waste Waste Stream

Beach Landing/

Logistics Camp

Worker’s

Construction

Camp

Power Plant Access

Roads/Bridges

from Beach

Landing

Installation

400kV line

Classification Reuse/Recycle/

Treatment/Disposal

Route

Decommission-

ing), sand

blasting

Chemical waste

(Sludge,

Scrapings

removed from the

generators, tanks

and pipelines)

X Hazardous Collection and disposal at

hazardous landfill by third

party waste contractor.

Oily solids may be bio-

remediated, or sludge’s

sent for landfilling.

Power Electronics

(Inverters,

transformers and

other power

electronics)

X Hazardous Re-use or re-sale of

transformers and

Collection and disposal of

non-recyclable e-waste at

hazardous landfill by third

party waste contractor

Pylons and

Cables

X Non-hazardous Reuse and/or recycle

ferrous and nonferrous

metals.

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Source of Waste Waste Stream

Beach Landing/

Logistics Camp

Worker’s

Construction

Camp

Power Plant Access

Roads/Bridges

from Beach

Landing

Installation

400kV line

Classification Reuse/Recycle/

Treatment/Disposal

Route

Power Plant -

Cooling Towers

and Boilers

By-products (dry

salt and minerals)

from Brine

collected in

evaporation

ponds / Brine

mixed with

cooling water

X Hazardous Treat Brine waste to

remove dissolved oxygen

and reuse as a cooling

agent for steel heat

exchangers (boilers) or

desalinate and return to

sea.

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5.0 WASTE MANAGEMENT ACCOUNTABILITIES

The section below details roles and responsibilities for all employees, contractors and suppliers to accomplish

the CTT project environmental objectives. In relation to waste management the roles and responsibilities are

outlined below:

Table 3: Waste Management Responsibilities

Role Responsibility

All employees

and contractors

Ensure the effective implementation of this Waste Management Plan (WMP) with respect

to their work area.

Ensure any potential or actual waste management issues, including environmental

incidents, are reported to the Project Manager or Supervisor.

Ensure equipment (relevant to task/area of responsibility) is maintained and operated in

a proper and efficient manner and as per design and operation specification.

Proponent Proponent is to ensure that the Managing Contractor conforms to this WMP. The

Managing Contractor shall be required to prepare a method statement, based on this

WMP, detailing his waste management activities for approval by the Proponent.

MITADER MITADER is the authority responsible for coordinating all environmental activities at

national level and for this reason it should be the main driver of the implementation of

environmental and social sustainability in all projects. This entity has the responsibility to

establish acceptance standards for the various environmental indicators through

legislation; and shall evaluate and jointly monitor the measures and actions proposed in

the WMP in order to prepare environmental audits as soon as appropriate management

deems necessary.

MITADER through the National Development Fund (FNDS) established a Hazardous

Waste Handling Facility at Mavoco, Beluluane district in Mozambique. The facility serves

the total territory of Mozambique. It includes a weigh bridge, an unloading packaging bay,

a treatment plant, land fill cells, a temporary storage facility for wastes that cannot be

landfilled, offices, a laboratory and other service buildings.

Contractor The Proponent’s representative, responsible for engineering, procurement and

construction management of the project. Construction management includes all social

and environmental management. In some instances, the Proponent may manage the

sub-contractors themselves, in which case the positions of Contractor and Site Engineer

will be members of the Proponent’s staff.

The Contractor is specifically responsible for:

Appointing appropriate resources for the implementation of this Plan

Ensuring the effective implementation of strategies designed to reduce waste from

the operations through communication with site staff and contractors

Ensuring any potential or actual waste issue is reported in accordance with legal

requirements, licences and corporate standards

Providing the necessary work environment and resources to ensure that all

processes are carried out under controlled conditions

Ensuring that operational changes consider the potential impacts of waste on the

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Role Responsibility

surrounding environment and adjacent landowners

Monitoring waste management performance of employees and project contractors

through regular audits and 6-monthly report review

Ensuring adequate resources are budgeted for in relation to waste management for

their task/project

Conducting regular inspections and audits of the work area to monitor compliance

with this plan.

Site Engineer The Contractor’s representative on site. Environmental staff (ESOs) shall report directly

to the Site Engineer. Referred to as ‘the Engineer’ in all specifications below.

Sub-contractor

(including all

sub-contractors

for construction

and other CTT

project activities)

The sub-contractor is responsible for the construction of all the works required by the

project. The WMP shall form part of the Contractor’s agreement with the Proponent and

shall be legally binding. The Contractor shall be responsible for the actions and

performance of all sub-contractors.

The sub-contractors shall be responsible for ensuring compliance with relevant

Mozambican legislation applicable to waste management.

The Contractor shall take proactive steps to ensure that the standards in the WMP are

met during all phases of construction/operations. These shall include, but not be limited

to, the following:

Employment of competent and dedicated members of staff to oversee the

implementation of the WMP. All employments and replacements of staff responsible

for the waste management of the contract shall be subject to the Managing

Contractor’s and the Proponent’s approval.

Active participation of such staff in the planning, construction and re-instatement of

the works

Regular interaction with the Managing Contractor’s environmental staff.

Ensure that the equipment required for waste management is maintained according

to the equipment specifications (including inspection and maintenance records

keeping).

Staff must be instructed about the relevant environmental sensitivities and the specific

measures that each employee will implement to meet the environmental protection and

waste management standards defined by the WMP.

Environmental

Site Officer

(ESO)

The Environmental Site Officer (ESO) shall be appointed under the Managing

Contractor’s staff and shall be employed on a full-time basis for the duration of the

contract in the case of all projects for which authorisation has been required by

MITADER.

The ESO shall:

Ensure the protection of the environment

Ensure that waste considerations are undertaken in the installation of all new

infrastructures for the operation

Identify waste management risks and impacts to the environment and assess

resources required to mitigate identified risks and impacts. Ensure that waste

management controls are implemented in accordance with this Waste Management

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Role Responsibility

Plan

Ensure all internal and external reporting requirements are met, including incident

reporting in accordance with established Environmental Management Systems

(EMS)

Ensure all reporting complies with internal and external monitoring standards,

protocols and regulations (Annex VII of Decree 83/20141)

Coordinate the collation and evaluation of monitoring data

Compile and maintain the hazardous waste inventory

Conduct (site) waste inspection regularly and report environmental performance to

Environmental Managers

Liaise with the Site Engineer and EC in the case of incidents, non-conformance or

any matter where the course of action is unclear

Prepare internal and external reports for review by the EC

Coordinate the implementation of any corrective actions and evaluate their

effectiveness

Provide visible and proactive leadership in relation to waste management on the

project

Assess new waste

Conduct waste audits as part of the Scheduled Internal Environmental Audits

Participate in the ongoing review of this Plan.

Environmental

Coordinator (EC)

The EC is a senior Proponent employee with extensive environmental work experience.

The EC shall liaise with any consultants or specialists, as necessary, during the course

of the project. The EC shall monitor environmental performance on the project and shall

review monthly non-conformance reports. The EC shall liaise with the Managing

Contractor regarding any significant non-compliance by the Construction Contractor and

the steps to be taken to rectify this.

The EC shall provide support to the ESOs and shall review the ESO monthly reports.

The EC shall update the WMP, when necessary, based on experience of the works. Any

updates shall be submitted to MITADER for authorisation.

The EC shall oversee the re-instatement of the site and provide final sign-off following

acceptable re-instatement.

Waste

Transportation

Contractor

Accredited waste transportation contractor.

1 An annual log of the sources, quantities and types of waste produced, transported, processed, recovered, disposed of or exported, and the occurrence of accidents shall be submitted to the Ministry that oversees the Environmental Sector by the end of the first quarter of the following year, and must be kept for five years.

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6.0 WASTE MANAGEMENT

6.1 Waste Management Hierarchy

An integrated waste management plan has been prepared in this section of the report to take into account the

internationally accepted waste hierarchy. The elements of the hierarchy are shown in Figure 9 below.

Figure 9: The waste management hierarchy

The philosophy of the waste hierarchy is that if less waste is disposed then it is less likely that there will be a

potential impact on the environment. The waste hierarchy encourages measures to be put in place to reduce

waste generated though more efficient processes and technologies, or at least to encourage the potential for

waste that is generated to be reused or recycled. Failing this, the hierarchy requires that waste be treated where

possible to reduce its volume or hazardous properties, or finally be disposed or incinerated.

Responsible waste management can be accomplished through the hierarchical application of the practices of

source reduction, re-use, recycling/recovery, treatment, and responsible disposal. This is provided for in article

4 of Hazardous Waste Management Regulation, Decree 83/2014 of 31 December and Regulations on Urban

Solid Waste Management, Decree 94/2014 of 31 December.

At all stages of the camp construction and operation, the first priority in terms of waste management will be to

minimise the amount and toxicity of all waste streams generated. Reducing the volume and toxicity of waste

generated will reduce the risks associated with the handling, storage, transport, treatment and disposal of the

waste. Waste minimisation can be accomplished applying the principles below:

1) Reduce - source reduction or ‘waste avoidance’ requires that waste managers examine ways of eliminating

or reducing waste at source. This is the first step in responsible waste management. In the event of

choices, this is the preferred alternative.

2) Reuse - where waste can be reused this is a preferred option. Reuse is different from recycling insofar as

it involves the reuse of a resource without changing its original form. The reuse of water would be an

example of this. Wherever possible, unused or partially used materials which are surplus should be

returned to the original suppliers.

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32

3) Recycling - involves the collection of materials that can be re-processed for further use, such as aluminium

cans and metal scrap. The separated material can be used as a product or raw material. There are local

markets for some recyclable materials such as plastic, metals and tyres. Market for the recycling of paper

and cardboard will be used to recycle waste paper and cardboard no longer utilised by project activities.

4) Resource recovery - involves the capture of energy or some other valuable benefit from the waste.

5) Incineration - involves the destruction of wastes, leaving a small quantity of ash to be disposed, and it is

found at the most advanced level of waste disposal/treatment.

6) Landfill - this is the final (least desirable) alternative which should only be used when all other reasonable

alternatives have been considered.

The above principles are applicable to both hazardous and non-hazardous waste.

The Environment Site Officer (ESO) shall identify and implement waste minimisation opportunities for waste

generated on site as part of the environmental audits and inspection process. Similarly, good housekeeping can

minimise the amount of waste generated by ensuring that, where possible, materials are used more than once,

and the use of general supplies is maximised before they are discarded, e.g. not discarding half full refuse bags.

To manage the project’s camps waste streams, it will be necessary to identify disposal routes in accordance

with the waste category assigned to the specific waste stream. Some waste may need to be stored temporarily

while the most appropriate treatment or disposal facility is identified, and arrangements made for transfer (e.g.

lead acid and dry cell batteries light bulbs and solvents).

7.0 WASTE MANAGEMENT PLAN

The guiding principle for a WMP is to adopt the waste hierarchy approach. The success of the implementation

of the WMP should be monitored against the various objectives and targets that have been set in this plan.

In line with the Principle of Extended Producer Responsibility, as described in Decree 83/2014, the responsibility

for implementing the waste management measures remains with the Proponent; however, where contractors

are appointed to perform certain activities, the contractor shall be responsible to ensure that these measures

are adhered to.

Table 4, Table 5, Table 6 and Table 7 present the procedural steps to be adopted when collection, segregating, storing, transporting and disposing of wastes as generated by CTT project activities. Responsibilities are also denoted accordingly.

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7.1 Non-hazardous Waste Management Table 4: Required Management Actions for Non-hazardous Waste

Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

Waste generation

and recycling Develop waste inventories. These

inventories will be updated throughout

the project, commissioning and

operations phases.

Stipulate the storage and disposal

requirements for each waste stream.

Develop waste management strategies

for each waste stream based on the

waste management hierarchy.

Prepare waste management

procedures for the specific scope of

work and expected waste types and

volumes.

Ensure worksites are kept free of litter

and that any litter is cleaned up

immediately.

Demonstrate efforts to reduce waste

volumes, where possible, and to

segregate and recycle waste where not

possible.

Contractor

ESO

Process

Engineers

Stores Managers

Workshop

Managers

Prior to

start of

project.

At all times

during the

project.

Record of waste

reduction and

recycling initiatives.

Recycling bins on

site.

Camp sites (worker’s

Camp and Logistics

Camp)

Waste handling

and storage Comply with applicable regulatory

requirements and standards regarding

the design and operation of all waste

storage areas (Decree 83/2014 of 31

Contractor

ESO

Process

Engineers

At all times Evidence of waste

storage containers.

Evidence of waste

segregation,

Construction,

Camp sites

(worker’s Camp

and Logistics

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

December; Decree 94/2014, of 31

December).

Segregate all waste streams at source,

where practicable (see section 1.1.1

below).

Label all hazardous waste containers in

accordance with the labelling system as

described in Annex IV of Decree

83/2014. This labelling system is

consistent with international guidelines.

Store all waste in appropriately

designed and clearly labelled waste

bins or waste containers.

Cover or close waste receptacles that

may present an issue for attraction of

pests and other fauna.

Regard any unidentified wastes as

hazardous waste and handle and store

such waste accordingly.

Separate combustible wastes from

ignition sources to minimise fire

hazards.

Inspect and empty temporary waste

bins/facilities regularly.

Securely store and contain all wastes

during transport to landfill facilities.

Stores Managers

Workshop

Managers

WWTP operators

separate

bins/containers for

different kinds of

waste.

Clear labels on bins

Evidence of waste

inspection records

Evidence of

inspection of waste

transport vehicles.

Camp).

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

Waste transport vehicle shall be in

secure skips or containers which are

covered during transport.

Waste transport

and disposal Comply with Mozambican waste

management regulations regarding

waste disposal (Decree 83/2014 of 31

December, Decree 94/2014 of 31

December).

Stipulate the storage and disposal

requirements for each waste stream.

For items that are marketable, re-use or

recycle waste materials. These

materials shall be separated from the

waste stream at their point of

generation and stored separately for

collection by an accredited recycling

contractor.

In accordance to the legislation, where

transport of waste off-site is required,

use a transporter that is certified by

Ministry that oversees the

Environmental Sector (MITADER).

Implement a Waste Transfer Note

(WTN), which is to be signed by the

Site Engineer.

Contractor

ESO

Process

Engineers

Stores Managers

Workshop

Managers

WWTP operators

operators

Waste

transportation

Contractor

At all times Record of waste

manifest signed by

ESO

Certificates of safe

disposal

Construction

Camp sites

(worker’s Camp

and Logistics

Camp).

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

Correlate the waste manifests with the

contractor’s waste management

method statement.

Retain the WTN for at least 3 years.

Collect waste sufficiently frequent to

ensure that there is no overloading of

the temporary storage at the site.

Have in place the means to respond

appropriately to spillages of waste

anywhere along the route within a time

limit acceptable to the Proponent.

Provide certificates of safe disposal to

the Site Engineer for all wastes

disposed at the waste site.

Where possible, dispose waste in a

discreet location at the waste site that

permits deposition and closure

independently of other waste, so that

due diligence can be verified and

documented.

Specific

requirements for

burying of waste

Prohibit the discard or burying of waste

materials (other than ash) on site. Contractor

ESO

Process

Engineers

Stores Managers

Workshop

At all times As per requirement Construction

Camp sites.

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

Managers

WWTP operators

Specific

requirements for

burning of

combustible

waste

Permit the burning of combustible, non-

hazardous waste in a burn pit, the location of

which shall be identified by the EC/ESO.

Contractor

ESO

Process

Engineers

Stores Managers

Workshop

Managers

WWTP operators

Daily Daily burning at

EC-identified

location

Absence of waste

unsuitable for

combustion in burn

pits.

Construction

Camp sites.

Specific

requirements for

incineration of

waste

Do not dispose of any waste by incineration

unless emissions from the incinerator meet

internationally accepted emissions guideline

levels / limits for small, temporary

installations (Basel Convention Technical

Guidelines on Incineration on Land, 2002;

IFC, Environmental Health and Safety

Guidelines for Waste Management Facilities,

1998; The European Waste Incineration

Directive, Directive 2000/76/EC on the

Incineration of Waste, 200).

Contractor

ESO

Process

Engineers

Stores Managers

Workshop

Managers

WWTP operators

As required As required

Specific

requirements for

composting of

organic wastes

Organic wastes; a composter will be used to

store these at the camps. Contractor

ESO

Process

Engineers

At all times As per specification Construction

Camp sites.

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

Specific

requirements for

recycling of

inorganic wastes

Separate inorganic waste into appropriately

labelled waste bins for recycling. Provide

bins for plastics, glass, waste packaging,

aluminium cans and scrap ferrous metal.

Uncontaminated wood shall be made

available to communities for their use (or

used in a wood chipper and used for

composting).

Stores Managers

Workshop

Managers

WWTP operators

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7.1.1 Segregation of Non-hazardous Waste

Regarding segregation of non-hazardous waste, the following measures shall be applied:

Organic and inorganic waste shall be separated at the work sites. Ensure bins are clearly labelled and / or

colour coded to indicate which waste types they contain.

For organic wastes, a composter will be used to store these at the worker’s camp.

Inorganic waste shall be collected in appropriately labelled waste bins and separated for recycle. There shall be separate bins for plastics, glass, and aluminium cans and scrap metal. These shall be collected at the camps and marketed for recycling.

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7.2 Hazardous Waste Management Table 5: Required Management and Monitoring Actions for Hazardous Waste

Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

Compliance with

legislation

Comply with the Mozambique

Regulations for the management of

Hazardous Wastes (Decree 83/2014 of

31 December). The specifications below

cover key requirements, but a full listing

should be obtained from the regulations

themselves.

Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers

From project

initiation and at all

times.

Compliance with Decree

83/2014 of 31 December Construction

Camp sites

Hazardous waste

method statement Prepare a Method Statement for

Management of Hazardous Waste

in accordance with Article 11 of

Decree 83/2014 of 31 December,

including the relevant information

required by Annexure II. The plan

shall include but not be limited to:

▪ An inventory of all hazardous

waste, together with estimated

quantities, documented in

accordance with the

classification system in

Annexures III and IX of the

regulations.

▪ Measures to comply with waste

hierarchy requirements for

Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers

WWTP operators

Before project

initiation as a basis

for licensing of the

activity

Authorisation by

MITADER Construction

Camp sites

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

minimizing hazardous waste

generation and recycling of

waste

▪ Measures to safely contain and

temporarily store hazardous

waste prior to collection.

▪ Measures to label hazardous

waste in accordance with

Annexure IV of the regulations.

▪ Measures to transport

hazardous waste in accordance

with Annexures VI and VIII of

the regulations.

▪ Details of the licensed disposal

site.

Waste generation

and recycling Develop waste inventories. These

inventories must be updated

throughout the project.

Stipulate the storage and disposal

requirements for each waste

stream.

Develop waste management

strategies for each waste stream

based on the waste management

hierarchy.

Prepare waste management

Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers

WWTP operators

Before

establishment

on site

At all times

during the

project

Record of waste

reduction and

recycling initiatives.

Recycling bins on

site

Construction

Camp sites

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

procedures for their specific scope

of work and expected waste types

and volumes.

Manage controlled waste as

required by the Mozambican waste

management Decree and

Proponent’s SHE policy.

Demonstrate efforts to reduce waste

volumes.

Recycle used oils and greases,

where possible, or dispose of them

appropriately according to the

regulation (Decree 83/2014).

Waste storage and

handling Comply with applicable regulatory

requirements and standards

regarding the design and operation

of all waste storage areas (Decree

83/2014).

Segregate all waste streams at

source, where practicable.

Line hazardous waste containers or

construct of materials that are

compatible with the wastes to be

stored. Keep containers in good

condition, free from corrosion, leaks

or ruptures and sealed to prevent

Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers,

Hazardous Waste

Transportation

Contractor

At all times

Within 7 days Evidence of waste

storage containers.

Evidence of waste

segregation,

separate

bins/containers for

different kinds of

waste.

Clear labels on bins

Evidence of

inspection waste

storage

facilities/containers

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

spillage.

Label hazardous waste in

accordance with the labelling

system required by Annexure IV of

Decree 83/2014 of 31 December

(Appendix C)

Keep Material Safety Data Sheets

for stored hazardous waste, where

available, at the following locations:

- the hazardous waste storage area

at the Camps

- the office of the Contractor’s site

manager

- the EC/ESO’s office

Regard any unidentified wastes as

hazardous waste and handle and

store such waste.

Locate spill kits at hazardous liquid

waste storage areas.

Handle waste chemicals in

accordance with the appropriate

Material Safety Data Sheet (MSDS).

Keep temporarily stored hazardous

waste at the work sites on pallets

underlain by a plastic liner. All waste

stored in this manner shall be

removed to the Base Camp within 7

Presence of spill

kits

Record of MSDS for

hazardous waste

materials

Manifest of waste

removal from site

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

days.

Ensure that storage at the Camps is

a concrete floored, bunded, facility,

covered to provide shade and

prevent ingress of rain. Bunded

areas shall include a trap to collect

wash-down water from cleaning of

the area. If this water is likely to

contain hydrocarbons, then the

washdown shall be treated as POC

water.

Fully secure the storage area, with

lockable gates, to prevent

unauthorised access.

Inspect and empty hazardous waste

storage facilities regularly.

Waste transport

and disposal Comply with Mozambican waste

management regulations regarding

waste disposal, as described in

Decree 94/2014 of 31 December.

Dispose of hazardous waste at a

licensed hazardous waste disposal

site.

Stipulate the disposal requirements

for each waste stream.

Implement a waste manifest which

Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers

At all times Record of waste

manifest signed by

ESO

Certificates of safe

disposal

Construction

Camp sites

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

must be signed by the Site

Engineer.

Correlate the waste manifest with the

contractor’s waste documentation.

Maintain the waste manifest for at

least 3 years.

Collect waste sufficiently frequent to

ensure that there is no overloading

of the temporary storage at the site.

In accordance with the legislation,

ensure that waste to be transported

off site is removed by a transporter

that is certified by MITADER.

Securely contain all wastes during

transport to hazardous waste

disposal sites or other means.

Have in place the means to respond

appropriately to spillages of waste

anywhere along the transport route

within a time limit acceptable to the

Proponent.

Provide certificates of safe disposal

to the Site Engineer for all wastes

disposed at the licensed waste site.

Specific

requirements –

Treat small quantities of soils

contaminated by hydrocarbons (less than Proponent

Contractor ESO

At all times Construction

Camp sites.

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

bioremediation of

contaminated soils

20kg) in-situ using bioremediation.

Where large quantities of contaminated

soils are involved (greater than 20kg) or

if there is the potential to cause pollution

to groundwater, surface water or

community water facilities, remove to the

area allocated by the EC at the Base

Camp for longer-term bioremediation

(over a surfaced hard standing area).

Monitoring of surface and ground water

in the areas with potentially impacted

soils will be necessary,a monitoring

programme is recommended for

inclusion in the o-EMP. Contractors shall

be responsible for the bioremediation of

their own contaminated soil until the

following standards are met:

There is no hydrocarbon odour.

The soil particles do not coagulate

as a result of hydrocarbon

contamination.

There is no visual evidence of

hydrocarbons in the soil.

Where there is uncertainty the soil

shall be sent for analysis.

Where soils are contaminated by

Process Engineers

Stores Managers

Workshop

Managers

WWTP operators

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

other hazardous chemicals they

shall be removed and disposed of

as per hazardous waste disposal

requirements, indicated in the

MSDSs.

Specific

requirements -

disposal of unused

chemical waste

Chemicals that are no longer used, or

are past their shelf-life date, shall be

stored in the hazardous waste storage

area at the Camps for interim storage

until disposal (toxic chemicals are

normally sent to incineration).

Contractor,

ESO

Process Engineers

Stores Managers

Workshop

Managers

WWTP operators

At all times Records of disposal Construction

Camp sites.

Specific

requirements -

pesticide use for

vector control

Should pesticides be used to control

the mosquito vector in and around

worker’s camps and work sites, they

shall be selected to minimise

negative effects on non-target

organisms.

The disposal of waste pesticide and

pesticide containers shall be as per

the requirements of Section 7.2.

Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers

WWTP operators

At all times Records of pesticide

use and eco-toxicity

management

Records of selection

procedure

Construction

Camp sites.

Specific

requirements -

cement storage,

Cement/aggregate shall be stored and

mixed on compacted ground in

designated areas. This ground shall be

Contractor

ESO

Process Engineers

Cement mixing As per requirement Construction

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

use and disposal lifted and disposed of in a waste site as

cover fill at the end of the construction

phase.

Stores Managers

Workshop

Managers

7.3 Wastewater Management

There are four types of wastewater streams would be expected from the CTT project activities. These are:

Potentially oily contaminated (POC) wastewater and storm water from maintenance areas and vehicle wash bays; this would be an intermittent stream;

Domestic wastewater, which includes grey water (from kitchens and washing facilities) and sewage waste;

Oily water effluent; and

The brine and ultrafiltration reject from the water treatment process.

Table 6: Required Management and Monitoring Actions for Hazardous Waste

Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Activities

Effluent Disposal

(oily wastewater)

(irrigation)

Dispose of effluent in line with

Mozambican regulations on

effluent water disposal

requirements and irrigation

(amended by Decree 67/2010 of

31 December.) and in line with

industry specific WB EHS

guidelines for effluent disposal.

Prepare a method statement

describing effluent management at

Camps that shall include, but not

Proponent

Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers

WWTP operators

Prior to initiation of

project activities

Method statement

available Construction

Camp sites

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Activities

be limited to:

▪ How effluent will be stored prior

to treatment.

▪ How the effluent will be treated

to meet the standards required

under Mozambican legislation:

Decree 18/2004 amended by

Decree 67/2010 of 31

December, “Regulation on

Environmental Quality and

Effluents Emission Standards”,

and under the EHS guidelines

for effluent disposal.

▪ Measures to ensure that there

will be no release of polluted

runoff from the site.

▪ Measures to prevent erosion at

any discharge point.

▪ The duration of the use of the

site.

Proponent/Managing Contractor

shall approve the Method

Statement prior to submission of

the effluent management method

statement to MITADER as a part of

wastewater licensing requirements.

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Activities

Potentially oil-

contaminated

wastewater

In work areas for servicing of vehicles

and equipment and other tasks where

oils and fuel are handled, route spillages

via appropriately sized mechanical oil

separators. Undertake planned

maintenance activities under roofed

areas to minimise contaminated storm

water.

Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers

WWTP operators

At all times POC-contaminated

areas contained, and

drainage routed

through mechanical oil

traps

Construction

Camp sites

Potentially

contaminated

storm water

Keep potentially oil-contaminated (POC)

storm water separate from other

drainage. If necessary, test and treat

POC storm water to remove

contaminants before being released into

the environment.

Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers

WWTP operators

At all times Incident reports and

corrective action report

where contaminated

water is generated

Construction

Camp sites

Compliance with

Mozambique oil

and grease

specification for

effluent

Ensure that water draining from POC

areas complies with the Mozambique

specification for oil and grease in

effluent discharged to the environment

(20 mg/l).

Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers

WWTP operators

At all times Compliance with oil

and grease standard

for POC-wastewater

released into the

environment

Construction

Camp sites

Vehicle wash bays Regards heavy vehicle wash bay(s) as

POC areas. Contractor

ESO

Process Engineers

Stores Managers

At all times Compliance with oil

and grease standard

for wastewater

Construction

Camp sites

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Activities

Workshop

Managers

WWTP operators

released into the

environment

Sand washing Should sand washing be necessary,

prepare a Method Statement for

approval by the Managing Contractor,

which shall include details of, but not be

limited to, the following:

Location of the washing process;

Estimated quantity to be washed

and water volumes required;

Source of water for washing;

Any additives to be used in the

washing process, including

chemistry and environmental

status (include MSDSs);

Methods for the management of

effluent, including TDS and the

monitoring thereof; and

Measures to prevent erosion as a

result of the washing process.

Contractor, ESO,

Process Engineers,

Stores Managers,

Workshop

Managers, WWTP

operators

Prior to sand washing Approved and

implemented method

statement

Construction

Domestic

wastewater

(irrigation)

Discard grey water (kitchens) into

French drains.

Drain sewage effluent from

worker’s Camp activities to a brick

or concrete-lined sump and treat it

in a package sewage plant, the

Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers

At all times Compliance with

domestic wastewater

specification as per

Decree 18/2004 of 2

June (amended by

Camp sites

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Activities

effluent from which shall comply

with the requirements of the

Mozambique regulations for

domestic wastewater (Decree

18/2004 Appendix IV, amended by

Decree 67/2010 of 31 December),

Environmental Quality and

Effluents Emission Standards

Regulation and the EHS guidelines

for domestic water for domestic

waste water.

Size the sewage plant in order to

cater for the maximum forecast

loads over the project construction

and operation periods. Undertake

regular compliance monitoring of

effluent quality.

In the event that the Contractor

proposes a septic tank and soak

away system, design this in

accordance with a recognised

standard such as ZA SANS 10400-

P:2010. The septic tank shall

accommodate at least three times

the expected daily flow rate

(approximately 90 litres per day

worker) and the soak away shall

WWTP operators Decree 67/2010 of 31

December)

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Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Activities

meet the requirements of the

standard or other recognised

standard.

Ensure that no septic tank and

soak away system is situated

closer than 150 m from a

community borehole.

For Camps and work sites, ensure

that there is a sufficient

complement of compositing toilets

available.

Brine and

Ultrafiltration reject

Evaporation – pond – design and

management. HDPE liner. Desludging Contractor

ESO

Process Engineers

Stores Managers

Workshop

Managers

WWTP operators

Prior to operations and

at all times

Approved and

implemented method

statement.

Construction

Operation

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7.4 Bio-medical Waste Management Table 7: Required Management and Monitoring Actions for Bio-medical Waste

Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

Disposal of medical

waste Separate all medical waste from

other waste. Place medical waste

in labelled bags in accordance with

the requirements of Decree

8/2003.

Separate infectious waste in yellow

plastic bags or, if not possible, any

other yellow impermeable plastic

bags or containers labelled with

the wording “Infectious Waste”.

Clearly identify all infectious waste

container through the label

“Infectious Waste” and the

international Infectious Waste logo

stamp.

Third party waste contractor to

collect for treatment/incineration.

Records of all medical waste

collected shall be kept and

submitted to the EC.

Contractor

ESO

Process Engineers

Stores Managers

Workshop Managers

As required Certificates of disposal Construction

Camp sites

Procedure for

medical waste

disposal

Dispose of the waste at the in

accordance with Proponent’s approved

medical waste management

procedures.

Thirdy party waste

contractor

As required Records of medical

waste disposal. Construction

Camp sites

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55

Description Requirements / specifications Responsibility Scheduling Performance

indicator(s)

Relevant CTT

Project

Activities

Off-site disposal of

medical waste

The third party waste contractor shall

provide the Proponent with the license

of the site(s) at which the waste is to be

disposed. In addition, ensure that the

site(s) receiving the waste provide

certificates of acceptance of the waste.

Contractor

ESO

Process Engineers

Stores Managers

Workshop Managers

As required Certificates of disposal Construction

Camp sites

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56

7.5 Other Wastes Those wastes which cannot be avoided, reused or recycled will be treated and/or disposed of in the most environmentally sound manner to minimize any potential human health and environmental impacts. Waste that cannot be avoided, reused or recycled and which are not suitable for incineration or disposal at a third-party landfill site will be temporarily and properly stored while an appropriate management route is identified.

7.6 Vehicles and Waste Contractors

Only waste contractors that can demonstrate they have the necessary authorisation from MITADER for

transporting the particular types of waste will be considered for the Camp’s waste management facility. The

following requirements shall therefore apply:

▪ The collection vehicle will be checked to ensure that it is designed for the type of waste and containers to be transported and that it is roadworthy.

▪ The contractor must be familiar with the requirements for the transportation of the type of waste (including hazardous);

▪ The frequency of waste collection and the interim measures for the storage of waste on site shall have to be appropriate to one another and would have to be such that the system as a whole does not pose an unacceptable risk to either the environment or human health and safety;

▪ The transportation contractor shall have in place the means to respond appropriately to spillages of waste anywhere along the route within a time limit acceptable to the CTT project (spill containment kits);

▪ Certificates of safe disposal shall have to be provided to CTT project for all wastes removed from site. Such certificates shall be issued by a recognized waste disposal operation; and

▪ The site at which such waste is disposed of shall have to comply with the corporate requirements of the CTT project and its shareholders. As such it shall have to be audited at intervals appropriate to the risk associated with the disposal operation.

7.6.1 Contractor Inspection

The ESO will inspect the Contractor periodically to ensure compliance with waste management requirements in

relation with project activities.

7.7 Waste Records

A Waste Register and copies of WTN will be maintained by Environmental Coordinator, as required by the

Mozambican waste management decree. The waste register shall contain data on the quantities of the different

types of waste that are generated by the project activities and the treatment/disposal option that is used.

All waste leaving the project sites will be accompanied with a WTN containing the following information:

Producer of the waste.

Site name & location.

Date.

Description of the waste (i.e. contents and volume).

Signature of the waste carrier.

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57

Name of disposal site.

8.0 TRAINING AND INDUCTIONS

Training is a critical component to raise awareness on the various impacts and associated management

functions of the Plan. Contractor shall ensure that all personnel responsible who are involved in activities that

could result in an environmental impact(s) and responsible for the execution of the tasks and requirements

contained within this Plan receive training and are competent.

Training shall take the form of, but not be limited to: induction training, use of educational posters and daily

environmental discussion topics prior to the start of each shift. During these training sessions, the following

principles shall be presented / discussed:

The Proponent’s corporate environmental, health and safety policies and applicable Mozambican

environmental regulations.

Their roles and responsibilities in achieving conformity with the requirements of the Camp

Camp Environmental Permits and their conditions; and

The Waste Management Plan and its procedures for managing identified environmental (and social)

impacts arising from Camp operations.

▪ Restrictions and procedures for collection, treatment and disposal of waste and hazardous

substances.

▪ Need to refrain from destruction of animals and plants, indiscriminate defecation, waste disposal

and/or pollution of local soil and water resources.

The contractor shall:

Describe the training and awareness requirements necessary for the effective implementation of the

Plan; and

Document training activity associated with the Waste Management Plan by means of a training needs

assessment, training matrix/plan and records of training undertaken.

9.0 INSPECTIONS, AUDITING, REPORTING, AND REVIEW

9.1 Inspections

An internal inspection schedule shall be developed and maintained for the CTT project. A record of all internal

inspections results shall be recorded and maintained. Actions arising from internal inspections shall be tracked

until their close out. Performance in respect of waste management shall be included in the monthly ESO reports.

9.2 Internal and External Auditing

An internal Audit Schedule shall be developed and maintained for the CTT project. A record of all internal audits

and the audit outcomes will be maintained. Actions arising from internal audits will be tracked until their close-

out.

Audits and/or inspections undertaken by external regulators will be facilitated via the Proponent’s Environmental

Manager. The findings of external regulatory audits will be recorded, and actions and/or recommendations will

be addressed and tracked

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58

9.3 Reporting to MITADER

Reporting on the CTT project shall be included in the Proponent’s six-monthly environmental performance report

submitted to MITADER. Additionally, an annual compliance audit report will be submitted to Government as set

by Government regulation for Category A projects.

9.4 Review of this Plan

The Proponent is committed to conduct activities in an environmentally responsible manner and aims to

implement best practice environmental management as part of a program of continuous improvement. This

commitment to continuous improvement means that the Proponent will review this Waste Management Plan

every 3 years or more often as required (e.g. in response to new information).

Reviews will address matters such as the overall design and effectiveness of the Plan, progress in waste

management performance, changes in environmental risks associated with waste management, changes in

business conditions, and any relevant emerging waste environmental issues appropriately covered by the Plan,

or measures that are identified to improve the Plan.

The Proponent may submit an amendment or addendum to the Plan to MITADER from time to time (for approval

under the EIA conditions for the CTT project).

All changes to the WMP shall be submitted to MITADER for approval. The World Bank shall be notified of any

material changes to the WMP.

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10.0 REFERENCES

AECOM, Sasol Beach Landing Assessment for the Mozambique Gas to Power Project, 2014

Basel Convention Technical Guidelines on Incineration on Land, 2002;

Decree 83/2014 of 31 December, Hazardous Waste Management Regulation.

Decree 8/2003 of 18 February, Bio-medical Waste Management Regulation.

Decree 94/2014 of 31 December, Regulations on Urban Solid Waste Management.

Decree 18/2004, amended by Decree 67/2010 of 31 December, Environmental Quality and Effluents

Emission Standards Regulation

IFC, Environmental Health and Safety Guidelines for Waste Management Facilities, 1998;

IFC, Environmental Health and Safety Guidelines for Thermal Power Plants, 2017;

Sasol Exploration and Production International Waste Management Plan, Revision 01, 2014.

Sasol Petroleum Mozambique, Sasol Petroleum Temane Limitada, PSA development and LPG Project:

Waste Impact Assessment, 2014

Sasol Petroleum Mozambique, Sasol Petroleum Temane Limitada, PSA development and LPG Project:

Environmental Impact Assessment, 2014.

Sasol Exploration and Production International, Future Exploration, Appraisal and Development Activities

in the Sasol License Areas, Waste Management Plan, 2017

Sasol Exploration and Production International, Future Exploration, Appraisal and Development Activities

in the Sasol License Areas & the Establishment of an Industrial Park, Inhambane Province, Mozambique,

Environmental Impact Assessment, 2017.

Sasol Exploration and Production International, Future Exploration, Appraisal and Development Activities

in the Sasol License Areas, Construction (Infrastructure) Environmental Management Plan, 2017

Sasol Exploration and Production International, Future Exploration, Appraisal and Development Activities

in the Sasol License Areas, Framework Decommissioning and Rehabilitation Plan (f-DRP), 2017

Sasol Exploration and Production International, Future Exploration, Appraisal and Development Activities

in the Sasol License Areas, Operational Environmental Management Plan, 2017

Sasol Exploration and Production International, Future Exploration, Appraisal and Development Activities

in the Sasol License Areas, Drilling Environmental Management Plan, 2017

Sasol Exploration and Production International, Future Exploration, Appraisal and Development Activities

in the Sasol License Areas, Oil Spill Response Plan, 2017

Sasol Petroleum Temane Lda, Central Processing Facility’s Construction Environmental Management

Plan, 2013

The European Waste Incineration Directive, Directive 2000/76/EC on the Incineration of Waste, 2000.

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Signature Page

Golder Associados Moçambique Limitada

Cândida Boavida Natalie Kohler

Environmental Consultant Senior Waste Consultant

CB/NK/up

NUIT 400196265

Directors: G Michau, RGM Heath

Golder and the G logo are trademarks of Golder Associates Corporation

c:\golder\projects\sasol\sasol mgtp\for submission\english\18103533-320978-12_ctt_waste mp_final_.docx

April 2019 18103533-320978-12

APPENDIX A

Annex V of Decree 83/2014 of 31

December

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Waste Disposal Operations

A. Operations that Do Not Lead to the Possibility of Recovery, Recycling, Regeneration, Direct

Reuse or Alternative Uses of Waste

Section A encompasses all disposal operations that occur in practice

D1 Deposit into or onto land (e.g. landfill).

D2 Land Treatment (e.g., biodegradation of liquid or sludge waste in soils).

D3 Deep injection (e.g., injections of pumpable discards into wells, salt domes or natural fault

lines).

D4 Impoundment (e.g. liquid or sludge discharge into pits, ponds or lagoons etc.)

D5 Specially engineered landfill (e.g. placement into lined discrete cells isolated from one another

and the environment)

D6 Discharge into a water body, except seas/oceans.

D7 Immersion in marine environment, including burial in the seabed.

D8 Biological treatment not specified elsewhere in this annex which results in compounds or

mixtures which are disposed of in accordance with one of the transactions mentioned in this

section.

D9 Physio-chemical treatment not specified elsewhere in this annex which results in compounds

or mixtures which are disposed of by one of the operations mentioned in this section (e.g.

evaporation, drying and calcination, neutralisation, precipitation).

D10 Incineration on land.

D11 Incineration at sea.

D12 Permanent storage (e.g. emplacement of containers in a mine).

D13 Mixing prior to any of the operations referred to in this section.

D14 Reconditioning before any of the operations referred to in this section.

D15 Storage prior to any of the operations referred to in this section.

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APPENDIX B

Characteristics of Waste and

Hazardous Substances

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Characteristics of Waste and Hazardous Substances

Class Code Characteristics

1 H1 Explosive

Substance or explosive residue; substance or solid waste, liquid (or mixture of

substances and or waste) that has the potential for chemical reaction producing gas

at a temperature, pressure and velocity such that it can cause damage to surrounding

areas.

2 H2 Substances consisting of compressed liquefied gases under pressure

Gases that are dangerous by virtue of being compressed, liquefied, dissolved under

pressure or cooled. These gases may pose additional danger and may be

asphyxiating, e.g. nitrogen; flammable e.g. butane; or toxic, e.g. chlorides.

3 H3 Flammable

Flammable liquids are liquids, liquid mixtures or liquids containing solids in solution or

suspension (for example paints, varnishes, lacquers, etc., not including substances or

waste classified differently due to their dangerous characteristics) that release

flammable vapours at temperatures not exceeding 60.5°C in the case of testing in an

open vessel, or not greater than 65.6°C in closed vessel tests. Since the results of

tests in open and closed vessels are not strictly comparable, and bearing in mind that

the results obtained by the same method often vary from each other, regulations

which deviate from the above values,in order to take into account these differences,

are considered compatible with the spirit of this definition.

4.1. H4.1 Flammable solids

Materials or solid waste other than those classified as explosives which during

transportation conditions are readily combustible and may through friction cause or

contribute to fire.

4.2 H4.2 Spontaneously flammable substances or waste

Substances or waste which are capable of spontaneous heating under normal

conditions of transport, or heating in contact with air and may therefore ignite.

4.3 H4.3 Substances which, on contact with water, give off flammable gases

Substances or waste which react with water and are likely to become spontaneously

flammable or emit flammable gases in dangerous quantities.

5.1 H5.1 Oxidisers or Oxidising Substances

Substances or waste, while not independently, may generally by yielding oxygen

cause or contribute to the combustion of other materials.

5.2 H5.2 Organic peroxides

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Class Code Characteristics

Substances or organic wastes containing the bivalent structure 0-0 that are thermally

unstable and may undergo sub-accelerated exothermic composition.

6.1 H6.1 (Acute) toxic substances

Substances or waste which, by ingestion or inhalation or skin contact, may harm

human health, cause serious injury or even death.

6.2 H6.2 Infectious substances

Substances or waste containing living micro-organisms or their toxins which are

known to or there is good reason to believe may cause disease in humans or

animals.

8 H.8 Corrosives

Substances or waste which, by chemical action, cause serious damage when in

contact with living tissue or, in the case of discharge, may seriously damage or

destroy others or the means of transport, and may also cause other hazards.

9 H.10 Substances which release toxic gases when in contact with air or water

Substances or wastes which on reaction with water or air are likely to emit toxic gases

in dangerous quantities.

9 H.11 Toxic substances (with delayed effects)

Substances or waste which, by inhalation, ingestion or skin contact may cause

delayed or chronic effects, including cancer.

H.12 Ecotoxic substances

Substances or wastes which do or may present immediate or delayed risks for the

environment, by bioaccumulation and or toxic effects on biotic systems.

9 H.13 Substances that, after disposal, may in some way give rise to other substances, such

as a product of leaching, having any of the characteristics mentioned above.

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APPENDIX C

Identification of Hazardous Waste

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Identification of Hazardous Waste

Type of Waste Identification Method Label type

Hazardous

Explosive Waste

Explosive hazardous waste containers should

be clearly identified by a black label with

orange background placed on all sides with

the international symbol for explosive

substances.

(Explosive)

Hazardous waste

consisting of

compressed or

liquefied gases or

under pressure

Hazardous waste containers consisting of

liquefied gases or under pressure shall be

clearly identified by a black or white label with

a green background placed on all sides with

the international symbol for substances

consisting of liquefied gases or under

pressure

(Compressed or liquefied gases

or under pressure)

Hazardous waste

consisting of

flammable liquids

Hazardous waste containers consisting of

flammable liquids shall be clearly identified by

a black label with a red background placed on

all sides with the international symbol for

substances which are flammable liquids

(Flammable liquids)

Hazardous waste

consisting of

flammable solids

Hazardous waste containers consisting of

flammable solids shall be clearly identified by

a black label with a red and white striped

background placed on all sides with the

international symbol for substances which are

flammable solids

(Flammable solids)

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Type of Waste Identification Method Label type

Hazardous waste

consisting of

spontaneously

combustible

substances or

waste

Hazardous waste containers consisting of

spontaneously combustible substances or

wastes shall be clearly identified by a black

label with a red and white background placed

on all sides with the international symbol for

substances or wastes which are

spontaneously combustible

(Spontaneously combustible

substances or waste)

Hazardous waste

consisting of

substances which,

on contact with

water, emit

flammable gases

Hazardous waste containers consisting of

substances which, on contact with water, emit

flammable gases shall be clearly identified by

a black label with a blue background, placed

on all sides with the international symbol for

substances which, on contact with water, emit

flammable gases

(Substances which, on contact

with water, give off flammable

gases)

Hazardous waste

consisting of

oxidisers

(oxidising

substances)

Hazardous waste containers consisting of

oxidisers shall be clearly identified by a black

label with a yellow background placed on all

sides with the international symbol for

oxidisers

(Hazardous waste consisting of

oxidisers)

Hazardous waste

consisting of

organic peroxides

or oxidizing

agents

Hazardous waste containers consisting of

organic peroxides or oxidizing agents shall be

clearly identified by a black label with a yellow

background placed on all sides with the

international symbol for organic peroxides

(Hazardous waste consisting of

organic peroxides)

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Type of Waste Identification Method Label type

Hazardous waste

containing

poisonous

substances

(acute)

Hazardous waste containers consisting of

poisonous substances shall be clearly

identified by a black label with a white

background placed on all sides with the

international symbol for poisonous

substances

(Hazardous waste containing

acute poisonous substances)

Hazardous waste

containing

ecotoxic

substances

Hazardous waste containers consisting of

ecotoxic substances shall be clearly identified

by a label with a white background and a

black tree or white fish placed on all sides

with the international symbol for ecotoxic

substances

(Hazardous waste consisting of

ecotoxic substances)

Hazardous waste

containing

infectious

substances

Hazardous waste containers consisting of

infectious substances (including infected

objects) shall be clearly identified by a black

label with a white background placed on all

sides with the international symbol for

infectious substances

(Hazardous waste containing

infectious substances)

Hazardous

radioactive waste

Hazardous radioactive waste containers shall

be clearly identified by a black label with a

yellow and white background placed on all

sides with the international symbol for

radioactive substances

(Hazardous radioactive waste)

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Type of Waste Identification Method Label type

Hazardous waste

containing

corrosive

substances

Hazardous waste containers consisting of

corrosive substances (including acids, bases

and batteries) shall be clearly identified by a

label placed on all sides with the international

symbol for corrosive substances

(Hazardous waste consisting of

corrosive substances)

Hazardous Waste

consisting of

various hazardous

substances and

articles which

cannot be

categorised under

other classes but

may be a hazard

during transport

Containers of hazardous waste, consisting of

various hazardous substances and articles

which cannot be categorised under other

classes but may be a hazard during transport,

should be clearly identified by a label placed

on all sides with the international symbol for

various hazardous substances and objects

(Hazardous Waste consisting of

various hazardous substances

and articles which cannot be

categorised under other classes

but may be a hazard during

transport)

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